*Chappell v Revenue and Customs Commissioners

Income tax – Annual payment. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) ruled on issues arising out of the taxpayer's appeal against the rejection by the Revenue and Customs Commissioners of his claim for a deduction from his total income in respect of certain payments relating to loan notes. Amongst other things, the tribunal accepted the argument put forward by the Revenue that, applying the Ramsay principle, the payments at issue did not fall within s 349 (1) of the Income and Corporation Taxes Act 1988 with the result that the taxpayer was not entitled to deduct those payments in computing his income for tax purposes.

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